The essentials
Citral and citronellol appear on perfume packaging because EU Regulation 1223/2009 on cosmetic products requires the declaration of identified fragrance allergens above defined concentration thresholds. The original list of 26 substances adopted in 2003 was expanded in the 2023 seventh amendment to cover 81 individual allergens and natural extracts, with mandatory compliance for all products placed on the EU market from 31 July 2026 (European Commission, Implementing Regulation 2023/1545, 2023).
The two molecules are among the most widely encountered in fine fragrance. Citral is a citrus aldehyde central to lemon, bergamot, lemongrass, and may chang. Citronellol is a terpene alcohol present in rose, geranium, and citronella oil. Both have a long history of safe use at normal perfumery levels, but both have been classified as established human contact allergens by the Scientific Committee on Consumer Safety (SCCS, Opinion SCCS/1459/11, 2012).
Declaration is required when concentration in the finished product exceeds 0.001% in leave-on cosmetics such as eau de parfum and eau de toilette, or 0.01% in rinse-off products. The disclosure aims to inform sensitized consumers, not to ban the ingredients. Labeling does not signal danger for the general population; it signals traceability for the small minority who have developed contact dermatitis to a specific allergen (Cosmetics Europe technical guidance, accessed 2026-05-29).
The EU legal basis for allergen declaration
The framework rests on Regulation (EC) No 1223/2009, the cornerstone of EU cosmetics law since 2013. Annex III of the regulation lists substances subject to restrictions; fragrance allergens are managed through an evolving Annex III appendix that the European Commission updates by implementing regulation when SCCS opinions justify revision.
Until 2023, only 26 allergens identified in the SCCNFP/SCCS opinions of the early 2000s were subject to declaration. Implementing Regulation (EU) 2023/1545, adopted in July 2023, extended the list to 81 substances based on the SCCS opinion SCCS/1459/11 and subsequent updates. The new entries include molecules already widely used in perfumery, such as carvone, methyl salicylate, vanillin, and several natural extracts.
What citral and citronellol actually are
Citral is a mixture of two geometric isomers, geranial (E-citral) and neral (Z-citral), with a sharp, bright, dry lemon-peel odor. It occurs naturally at concentrations of 65 to 85% in lemongrass oil and 75 to 90% in litsea cubeba (may chang), and at lower but significant levels in lemon, bergamot, and verbena. Citral is also produced synthetically at industrial scale from beta-pinene or from isobutylene chemistry by Givaudan, BASF, and Symrise.
Citronellol is a primary terpene alcohol with a soft, slightly rosy, citrus-fresh odor. The (-) enantiomer dominates in geranium oil; the (+) enantiomer is found in rose otto. It is one of the workhorses of the rose accord and appears in nearly every floral fragrance built around rose, geranium, or citronella. Both molecules are present in the IFRA Code as substances with full or quantitative restriction depending on product category (IFRA Standards, 51st amendment, accessed 2026-05-29).
Declaration thresholds and product categories
EU thresholds depend on whether the product stays on the skin. For leave-on cosmetics, including perfumes, eau de toilette, body oils, and creams, the declaration threshold is 0.001% (10 parts per million) of the finished product. For rinse-off products such as shower gels, shampoos, and soaps, the threshold rises to 0.01% (100 ppm). This distinction reflects the shorter contact time of rinse-off categories.
Because citral and citronellol are commonly used at 0.05 to 5% of the finished perfume depending on the composition, they almost always exceed the leave-on threshold in any fragrance built around citrus, rose, or geranium. This is why nearly every modern eau de parfum lists at least one of them in the INCI declaration on the carton or bottle base.
SCCS opinion and the 2023 seventh amendment
The Scientific Committee on Consumer Safety opinion SCCS/1459/11, adopted in 2012 and revised in 2013, reviewed clinical and epidemiological data on contact allergy from fragrance ingredients. It identified a set of established human contact allergens, a set of likely contact allergens, and a set of substances requiring further evaluation. Citral and citronellol both fall in the established category, alongside oakmoss extract, hydroxycitronellal, and the discontinued Lyral.
The seventh amendment to Annex III, published as Implementing Regulation (EU) 2023/1545, gave manufacturers a transition period: products manufactured from 31 July 2026 must comply, with products already on shelves allowed to be sold through 31 July 2028. This is one of the longest transition windows in recent cosmetic law, reflecting the scale of relabeling required across the industry.
Practical impact on niche perfumery
For niche houses, the 2023 expansion mainly means longer ingredient declarations on the back panel. The molecules themselves remain permitted at normal usage levels; only the disclosure changes. Houses with rose, citrus, and aromatic compositions, such as Frederic Malle, Diptyque, Atelier Cologne, and Goutal, see the longest expanded lists.
Some houses use the relabeling cycle to update their packaging entirely. Others keep stickers temporarily as a transitional measure. The cost of the change falls heavier on small artisan houses with limited print runs than on large groups with integrated supply chains, but the regulation makes no exemption for size or sales volume.
Reading an INCI list as a consumer
Allergens are listed at the end of the INCI declaration, after the generic mention parfum or fragrance. They appear in descending order of concentration when above 1% and in any order below that threshold. A typical line reads: parfum, limonene, linalool, citral, citronellol, geraniol, eugenol. The presence of multiple allergens is the norm, not the exception, for a fragrance built on naturals.
For consumers with no known fragrance allergy, the list carries little practical meaning. For consumers diagnosed by a dermatologist with sensitivity to a specific molecule, the declaration enables informed purchasing. This is the design intent of the regulation: enable the small at-risk population, without restricting the majority (Cosmetics Europe, technical guidance on allergen labeling, accessed 2026-05-29).
Sources
- European Commission, Implementing Regulation (EU) 2023/1545 amending Regulation 1223/2009 as regards the labeling of fragrance allergens, July 2023.
- Scientific Committee on Consumer Safety (SCCS), Opinion on Fragrance allergens in cosmetic products SCCS/1459/11, 2012, revised 2013.
- IFRA Standards Library, 51st amendment to the Code of Practice, citral and citronellol entries. Accessed 2026-05-29.
- Cosmetics Europe, technical guidance documents on fragrance allergen labeling. Accessed 2026-05-29.